Federal Court Strikes Down New HSR Form

On February 12, 2026, the Eastern District of Texas overturned the Federal Trade Commission's (FTC's) new Hart-Scott-Rodino (HSR) Act notification form that has been in effect for the last year. The HSR Act requires parties contemplating deals exceeding certain thresholds to file a premerger notification form with the FTC and the U.S. Department of Justice Antitrust Division. The HSR form was largely unchanged since it was first adopted in 1978 until October 10, 2024, when the FTC promulgated a Rule implementing a new HSR form that significantly expanded the scope of information and documents required to be submitted. The new HSR form added 20 categories of document and information requests and tripled estimated compliance costs. The new HSR form went into effect February 10, 2025. Now, almost exactly a year later, a federal district court has struck down the FTC Rule implementing the form.